Free Order on Motion for Waiver of Speedy Trial Act - District Court of Delaware - Delaware

Case 1 :07-cr-00146-GIVIS Document 17 Filed 12/O4/2007 Page 1 of 2
.- IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, V :
Plaintiff,
v. Criminal Action No.07-146-GMS
HUGO OLGUIN-LOPEZ, zz
a/M2 Hugo Lopez-Olguin, :
a/Ida Anthony R. Sanchez, :
Defendant.
MOTION AND ORDER TO EXCLUDE TIME
COMES NOW the United States of America, by and through Colm F. Connolly, United
States Attorney for the District of Delaware and Keith M. Rosen, Assistant United States
Attorney, and hereby moves this Honorable Court to exclude under the Speedy Trial Act, 18
U.S.C. § 3161, the time from the date of its Order granting this Motion until the rescheduled
motions deadline in this matter. In support thereof, the government states as follows:
1. The defendant was arraigned in this matter on November 8, 2007. At that time, ·
Magistrate Judge Thynge entered an Order granting the defendant until November 27, 2007, to
file any pre-trial motions, and excluding the time from November 8, 2007, until November 27,
2007, under the Speedy Trial Act ("the Act").
2. The defendant did not file any motions prior to the November 27, 2007, deadline.
By letter dated November 29, 2007, Thomas Pedersen, Esq., entered his appearance on behalf of
the defendant and requested an extension until December 27, 2007, to tile motions. The
defendant had been represented by Ubel Velez, Esq. ` I

Case 1 :07-cr-00146-GIVIS Document 17 Filed 12/O4/2007 Page 2 of 2
3. The government does not oppose the requested continuance of the motions
deadline. Further, the government respectfully submits that additional time to permit the
defendants new counsel an adequate opportunity to review the discovery in this matter and tile `
any pre-trial motions is in the interest of justice. Accordingly, the government submits that this
delay should be excluded under the Speedy Trial Act, and asks this Court to enter an Order
excluding time tmder the Act Hom the date of said Order until the date of the rescheduled
motions deadline. See 18 U.S.C. § 3l6l(h)(8)(A).
Respectfully submitted,
COLM F. CONNOLLY
United States Attomey
BY¤
Keith M. Rosen
Assistant United States Attorney
Dated: December 3, 2007
{tt
IT IS S0 ORDERED this Ul day of , 2007.
Honorage Gregory M. Sleet
Chief Judge
United States District Court
District of Delaware
F I L E D
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Case 1:07-cr-00146-GMS

Document 17

Filed 12/04/2007

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Case 1:07-cr-00146-GMS

Document 17

Filed 12/04/2007

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